IMPORTANT: If you choose to accept this Policy you must do so as it is
presented to you – no changes will be accepted by HMC.

What types of personal information does HMC collect?

In addition to the information collected from all users of our web sites (which
is governed by the Internet Privacy Policy, we collect the following information from our VOILÀ Hotel
Rewards Members:

Registration. When you register your account, you will be required to
provide your name, postal and email address, telephone number, date of birth, preferred
language, demographic information, room preferences, user name and password. Once
your account is registered, an online profile is created which you may access by
entering your username and password. Creating an on-line profile via your personal
account makes it more convenient for you to make reservations by eliminating the
need to repeatedly enter personal preference information. In addition, if you so
choose, you can include your credit card information in your account profile. Your
credit card information will be used for subsequent reservations to increase reservation
speed and eliminate the need for you to repeatedly enter your credit card information.

Rewards Reservations. When you book a Rewards Reservation, purchase VOILÀ
Hotel Rewards Points or make a reservation for travel services, we may ask for your
name, account number, postal and email address, along with other information such
as credit card information, currency preferences, frequent traveler number, frequent
flyer or partner program affiliation, lodging preferences, early/late check-in/check-out
and special account information such as corporate account number, group or convention
code, or travel agent number. The information is made available to the applicable
hotel for the purpose of meeting your request, and to send them special offers based
on your country of residence.

Points Transfers. For point transfer, members transferring their points
to another member must submit the other members name and account number.

Requests for Information. Other information may be collected as part of:
(i) fulfilling information and other requests, (ii) improving service to your account
and preferences by keeping you informed of your account status and activities; or
(iii) responding to communications from us.

Travel History. We will keep a history of all your reservations of travel
services and accommodations in your account information unless you choose to edit
your account information as described below in this Policy. Such information is
recorded to meet your requests and to make more appropriate travel recommendations
to you. Financial details, i.e., members’ total spend at each hotel) will be shared
with hotels participating in the VOILÀ Hotel Rewards Membership program to perform
our agreements with the hotels, but only on an accumulated basis.

Where Will We Store and Maintain the Information?

We maintain the VOILÀ Membership database in the United States. By providing
personal and other information to us, you consent to the collection, processing
and transfer of such information to the United States and other countries or territories
which may not offer the same level of data protection as the country in which you
reside, in accordance with the terms of this Policy. Due to the global nature of
our business, personal information will be shared with affiliated companies, hotels,
third party services providers, and as described below in this Policy, entities
which may be located in countries which may not offer the same level of data protection
as the country in which you reside.

How Will We Use Personal Information?

We will use personal information to fulfill the purpose for which it was provided,
as otherwise described in this Policy, and as disclosed at the time the information
is requested. In particular, we will process the information for member fulfillment
which includes our database center, point allocation, tier upgrade/downgrade, sending
fulfillment kits from our fulfillment house, and member communication.

Does HMC Share Personal Information?

We may share the information with our affiliated
companies, as well as with hotels participating
in the VOILÀ Hotel Rewards Membership program. Hotels will use the information to
register you with the program, for member recognition, benefits, and for point allocation.
We use our reasonable efforts to ensure that the hotels will also protect your personal
information.

We contract with other companies to perform various functions necessary to meet
your specific requests, administer the VOILÀ Hotel Rewards program and our websites,
communicate news and deliver promotional materials via email, and to process credit
card transactions. We will share with these other companies only that personal information
they require to fulfill your orders. These companies agree that they will not use
or disclose that personal information for any other purpose.

We may partner with other companies to offer you additional products or services,
such as rental car companies or air carriers. If you sign up for any of these additional
products or services, we will share the information that is necessary for these
other companies to provide the products or services you have signed up for. This
Policy will not cover the use of your personal information by these other companies.
We encourage you to read each other company’s privacy policy before signing up for
any of its products or services.

Other than as explained in this policy, we will not disclose any personal information
we collect from you to others without your permission, except in certain limited
circumstances: (a) to protect the security of our websites; (b) to protect ourselves
against liability; (c) in response to legal process; (d) if we believe in good faith
that the law requires it; or (e) in connection with a sale, merger, acquisition,
reorganization, recapitalization or similar transaction involving our business or
company.

Special Offers. As part of the registration process, you will be asked
to give your permission to receive telephone and email advertisements, updates and
promotions about the VOILÀ Membership program, products and services of HMC, participating
hotels, and companies offering additional products and services requested by you.
We hope you will find these items interesting and informative. We typically use
third party providers to call or send emails. These service providers are contractually
prohibited from using the information for any purpose. We provide you with the ability
to define and modify your preferences online at anytime including unsubscribing
from all telephone and email marketing communications. In addition, every time you
receive a marketing or promotional call or email from us, you will be given the
opportunity to opt-out of future calls or emails.

What if the Policy Changes?

This Policy is effective as of November 1, 2006. HMC may amend this Policy from
time to time in order to meet changes in the regulatory environment, business needs,
or to satisfy the needs of our members, participating hotels, or strategic marketing.
A notice will be posted on this Site whenever the Policy is changed in a material
way.

Can I Review or Change My Personal Information?

If you have comments or questions regarding HMC’s data privacy practices or this
Policy, or if you want to review, correct, or change personal information about
you, you may contact us via email at privacy@vhr.com, by telephone (+1949-833-8000),
or postal mail (4701 Von Karman Ave, Suite 300, Newport Beach, California 92660,
USA). If you wish to review your preferences, you can do so by logging into your
VOILÀ account at www.vhr.com.

SPECIAL NOTIFICATION FOR CALIFORNIA RESIDENTS: Although HMC does not share
personal information with unrelated third parties for their own direct marketing
purposes, many participating VOILÀ hotels, which are separately owned and operated,
are permitted to use the personal information they receive from HMC to market their
hotels. If you are a customer who resides in the State of California, you may request
from HMC information about our disclosures of certain categories of personal information
to third parties for their direct marketing purposes. Such requests must be submitted
to us by email at privacy@vhr.com. This request
may be made no more than once per calendar year. We reserve our right not to respond
to requests submitted other than to the address specified in this paragraph.